Privacy Policy

We are committed to protecting your personal data and privacy.

This Privacy Policy explains how we collect and store information you provide via the Thornhill Fundex website (the “website”)

We will uphold the following principles:

• To clarify how we collect and process your personal information:

Our aim is to enable you to make informed choices about how your personal data is used and processed. This website exists for that purpose. To support this, we employ a range of methods and processes to provide relevant information about the use of personal data.

Should it be necessary for you to have specific details, we will provide the information at the appropriate date and time.

We’re happy to answer any questions and provide clarification on legal restrictions. You can contact us by email at: info@thornhill-fundex.com

• Personal data will be used solely for the purposes set out in this policy.

We may process Personal Data for various purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, maintaining and delivering the Services, complying with legal and regulatory obligations, and carrying out administrative and business activities that support the delivery and use of the Services

We also process personal data to better understand your preferences and needs.

• Access essential tools to protect your rights regarding personal data:

To uphold your rights, we offer comprehensive support. Contact us at any time to request access to your personal data. We can correct or delete it, halt its use for specific or general purposes, and transfer the information to you or a third party. We will honour your requests

• Safeguard your personal data

While we cannot guarantee the absolute security of your personal data, we assure you that we will continue to employ a range of measures and best practices to help keep it safe

We maintain a comprehensive privacy and security policy.

1. What does the scope cover?

This policy sets out the categories of personal data the company collects from individuals, how it is processed, shared with third parties and safeguarded, among other details.

This Policy relates to information about an identified or identifiable natural person. An identifiable natural person is anyone who can be identified directly or indirectly, including by reference to additional information we hold or can access.

The Policy defines ‘processing’ as any activity that involves the use or collection of personal data. This covers the management, organisation, and storage of such data.

Our services are aimed at a general audience and are not intended for anyone under 18. We do not knowingly solicit or collect information from individuals under 18. We also do not knowingly permit such individuals to use our services. If we become aware of such information, we will delete it as promptly as possible.

2. What personal data do we hold about you?

When you access our services and channels or visit our website, we collect personal information. We may request your personal information in certain situations. In other instances, we collect it by analysing your use of our services and channels or by receiving it from our third-party partners

3. You are not required to disclose personal information to the company, and the consequences

However, you are under no obligation to provide us with personal data. In some cases, though, you may need to supply certain personal data. Without it, we may be unable to provide our services, or users may be unable to access the website.

4. What types of personal data do we collect? When you visit our website, we may collect the following personal information:

This includes details of your online activity log; traffic data (such as your IP address and the date and time of access); your language settings; software crash logs; the type of browser used; and information about the device you use. The information collected is not personal data and cannot be used to identify you

Personal Data We receive from you: Any personal data you voluntarily provide to Us when you connect to a third-party online trading platform through Us

Personal data you provide directly to third‑party platforms to facilitate transactions: this may include your full name, address, telephone number and email address.

5. The lawful basis and purposes for processing personal data

The company processes your personal data for the purposes described in this section, in accordance with the relevant legal basis.

Without a lawful basis, the company cannot use your personal data. The legal bases on which the company may process your personal data:

• You have consented to the processing of your personal data for one or more purposes, including when you provide personal information via the website for us to transfer it to a third-party trading platform
• The company or a third party may need to process data to fulfil their legitimate interests. For example, to improve our services or to establish, exercise or defend legal claims.
• Processing is required to comply with a legal obligation.

Contact us by email for further details on the processing required to safeguard legitimate interests.

Below is a list of reasons and legal bases on which we may use the personal data you provide to us

6. Disclosure of Personal Information to Third Parties

The company may also share personal data with third-party service providers that support our operations, including hosting and storage providers, IP address services, and user experience analytics.

You may also request that we share specific personal data about you with third-party trading platforms. In such cases, we will provide the personal data you supply to those third-party platforms. Their privacy policies govern the use of your personal information. Your personal information may be shared with multiple trading platforms

The Company may share personal data with affiliated entities and business partners that can supply the Company with resources required to enhance and improve the products and services it provides to its customers.

Where necessary to protect the rights of third parties or the Company’s assets, personal data may be shared with regulatory, local or other competent authorities

We may also share your personal data with potential investors or buyers, or with lenders to the company or any other group company, in connection with such a transaction (including the transfer or sale of assets belonging to the company or any other group company) or as part of any merger, restructuring, consolidation, or insolvency of the company or any other business within the group

7. Cookies and Third-Party Services

We may use third-party services, such as advertising providers on our website or analytics companies. These providers may also use cookies or other technologies.

Cookies are small text files stored on your device when you visit or use this website. They collect information about your preferences and browsing behaviour to improve your experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistical reporting and analytics

Some of the cookies we use are session cookies. These are temporarily stored on your device and last only for a short time until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the website recognise you as a returning user and make it easier for you to return to the site

Types of biscuits:

We may use them for their intended purpose

Cookies are blocked or have been deleted

To block or delete cookies, adjust your browser settings. The links below will guide you through the process for a range of popular browsers

• firefox
• Microsoft Edge
• Google Chrome
• safari

However, please note that some or all of the website's functions and features may not work as expected if this occurs

ONLINE TRACKING NOTICE

The Company will retain your personal data only for as long as needed to fulfil the purpose set out in this policy, or longer where required or permitted by applicable laws, regulations, policies, and orders

We will share your information with third-party trading platforms for 12 months. If you consent, we will continue to share your data for a further 12 months

We regularly review the Personal Data we hold to confirm whether it remains necessary.

9. Transfer of personal data to a third country or an international organisation

Your personal information may be transferred to other countries, including to third countries (that is, countries other than the one in which you reside), or to international organisations or jurisdictions. When such transfers occur, the company takes all necessary steps to protect the personal data you provide and implements appropriate safeguards to ensure that data subjects are able to assert their rights and access effective legal remedies

These protections and safeguards apply to all residents of the EEA (European Economic Area)

• Transfer to a third country or an international organisation that the European Commission has determined provides an adequate level of protection for personal data transferred to it in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”)
• The transfer is made under a legally binding and enforceable agreement between public entities or authorities, pursuant to Article 46(2)(a).
• The transfer was undertaken in accordance with the European Commission’s Standard Contractual Clauses adopted under Article 46(2)(c) of the GDPR. The European Commission’s Clauses can be accessed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

The Company can provide details of the security measures it uses to safeguard your personal data when it is transferred to third countries or international organisations. To request this information, please email info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented appropriate organisational and technical measures to safeguard personal data. These measures prevent accidental or unlawful destruction, loss, or alteration of personal data

We cannot guarantee or warrant that your personal data will always be secure and error-free. We do not accept responsibility for any intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, without limitation, disclosures resulting from transmission errors, unauthorised access by third parties, or any other circumstance beyond our control

If we are legally obliged or required to meet conditions beyond our control, we may need to disclose your personal data to third parties, such as government authorities. In these circumstances, we cannot guarantee that third parties will protect your personal data

Transmitting personal data over the internet is never completely secure. The Company cannot guarantee the security of any personal data you send to us via the internet

11. Links to third-party websites

Our website may include links to third-party websites and applications. These sites and apps are not operated or controlled by the company. We are not responsible for any collection or processing of personal data carried out by them. This Policy does not cover activities conducted on those external sites or apps.

When you visit third-party websites or apps, we recommend reviewing their privacy policies before deciding whether to access or use their services. We also advise only sharing personal data once you are comfortable with their practices

12. Updates to this Policy

This policy may be updated at any time. If we make changes, we will notify you by updating the policy on our website accordingly. In addition, for material changes, we will take reasonable steps to contact you via methods we deem appropriate and will also post a notice on our website. Unless stated otherwise, amendments take effect once the revised policy is published

13. Your rights in relation to your personal data

You have the right to ask us to verify the accuracy of the personal data we collect about you, correct any mistakes, and delete any personal data we do not need. You may also restrict the scope and types of processing of your personal information

If you are a resident of Zimbabwe, please see this page:

You are entitled to these rights concerning the personal data you provide. To exercise them, please send an email to the address below.

Access rights

The Company can verify whether the personal data being processed about you is accurate. If so, you can access your personal data

The Company will provide an electronic copy of the personal data it currently processes and may charge a reasonable fee for any additional copies. The data will be available electronically upon request

The right of access to personal data must not infringe the rights and freedoms of others. If a request would adversely affect another person’s rights or freedoms, the company may refuse to comply or limit how it responds.

Right to rectification

The Company may correct inaccurate personal data, and you have the right to request the rectification of any incomplete personal data relating to you, taking into account the purpose of processing

Right to Deletion

The following reasons apply: (a) Personal data is no longer needed for the purpose for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time, for reasons specific to your situation, to the processing of your personal data based on legitimate interests pursued by us or a third party; (e) personal data has been processed unlawfully; or (f) personal data must be erased to comply with the company's legal obligation

This right does not apply where processing is necessary (a) to comply with a legal obligation under EU law or the law of a Member State; or (b) to establish, exercise, or defend legal claims.

Processing restrictions

If you are concerned about the accuracy of your personal data, you may ask the company to restrict the processing of your personal data

If you ask us to restrict the processing of your personal data, we will retain it only with your consent, to establish, exercise or defend legal claims, to protect another person’s rights, or where there are overriding public interest reasons in the European Union or a member state

The right to data portability

If processing is carried out by automated means and is based on your consent or a contract to which you are a party, you have the legal right to review the personal data you have provided to the company

You have the right to request that your personal data be transmitted directly by the company to another controller, where technically feasible. Exercising your right to data portability does not affect the rights you have under the right to erasure. The right to data portability must not interfere with the rights or freedoms of others

Right to object

You may object at any time to our use of your personal data where it is based on legitimate interests pursued by the company or a third party. This includes any profiling based solely on those legitimate interests. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds that override your rights, freedoms and interests, or the processing is required for the establishment, exercise or defence of legal claims

You have the right to object to the processing of your personal data for direct marketing at any time

Right to decline approval

You may withdraw your consent for us to process your personal data at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal.

You have the right to lodge a complaint with your relevant supervisory authority.

You have the right to lodge a complaint with a supervisory authority in an EU Member State responsible for protecting individuals’ fundamental rights regarding the processing of personal data within the European Union

Regulations of the European Union and Member States may restrict your rights in relation to your personal data, as set out in section 13.

We will supply the requested information, in line with your rights under section 13 of this agreement, within one month of receiving your request. If necessary, this period may be extended to up to two months, depending on the nature and volume of requests. We will inform you of any extension, and the reasons for it, within one month of receiving your request.

Provided this does not conflict with section 13 of the law, information you request under your rights in section 13 will be provided free of charge. If your request is unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or communicating the action requested. We may also decide not to act

If we have any doubts about the identity of the person who submitted your request, we may ask for additional information.